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The year 2011 was marked by several important trends with respect to FCPA enforcement, but the most notable one is that it was the year in which more FCPA cases were litigated at trial than in any year previous

On October 22, 2010, the Fifth Circuit issued United States v. Jeong, which held that the jurisdictional provisions of the OECD Convention did not bar multi-national enforcement of the same bribery offense by OECD countries

The Department of Justice (DOJ) has issued two Foreign Corrupt Practices Act (FCPA) Opinion Procedure Releases (Opinion Releases) this year - Opinion Releases 10-02 and 10-03 - that provide guidance with respect to the types of due diligence and controls companies should consider with respect to third-party business relationships in foreign business contexts where the circumstances indicate corruption risk

Department of Justice Sentencing May 6, 2010 Jean Fourcand, who had pleaded guilty on February 19, 2010, to money laundering in connection with the bribery scheme involving Florida-based telecommunications companies and former Haitian official Robert Antoine, was sentenced to six months in prison for his role in the scheme

Daimler AG, a German corporation, and three of its subsidiaries resolved FCPA charges that stemmed from a long-standing practice of paying bribes to foreign government officials in at least 22 countries, including China, Croatia, Egypt, Greece, Hungary, Indonesia, Iraq, Nigeria, Russia, Thailand, Turkey, Turkmenistan, Uzbekistan, and Vietnam

In Opinion Release 10-02, the Department of Justice considered a request by a United States-based non-profit microfinance institution (MFI) that desires to change the status of its wholly-owned Eurasian subsidiary (Subsidiary) from a non-banking MFI to that of a licensed bank

Robert Antoine, a former official of the Republic of Haiti's state-owned national telecommunications company, was sentenced to 48 months in prison for his part in a money-laundering conspiracy in connection with a foreign bribery scheme involving Antoine and Floridabased telecommunications companies

Brown and Steph, employees at Willbros Group, Inc., pleaded guilty for their role in a bribery scheme in which more than $6 million in bribes was giving to government officials in Nigeria to assist Willbros Group in obtaining and retaining a natural gas pipeline system contract worth $387 million

On January 21, 2010, FCPA charges were filed against the informant who led the government to the 22 individuals indicted in the FCPA sting operation made public two days earlier, confirming that the individual in question, Richard Bistrong, had been cooperating in order to seek leniency in his own prosecution